Sydney CBD Light Rail

To whom it may concern:
Attached is a Submission to the CSELR EIS from NRMA Motoring & Services. The submission includes an attachment - NRMA's submission to the Sydney City Centre Access Strategy.

See submission attached.

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See attached.

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Acting for the Owners of Strata Plan 61895. See attached.

See attached.

Please see attached submission.

20 December 2013
Department of Planning and Infrastructure
Sydney NSW 2001

CBD and South East Light Rail Project

I support the Light Rail as a Public transport solution for the CBD and inner east. It will contribute to easing transport-related problems across the CBD and inner east and be a valuable piece of infrastructure for Surry Hills. I have been a resident of Surry Hills for 20 years; owning and living in properties in Nobbs and Bourke St (current residence). I believe the proposed CBD and South East Light Rail (CSELR) project will provide a much-needed, new transport option. However, there are a number of impacts that have not been adequately addressed in the Environmental Impact Statement (EIS).

Reduction of Devonshire St to single-lane, eastbound vehicle thoroughfare
Devonshire St is the ONLY LOCAL east-west corridor in Surry Hills (SH). I use this daily for my commute to the University of Sydney. Without Devonshire St, I would be forced onto Foveaux, Cleveland or Albion Streets. These are major arterial roads that are congested; or in gridlock, in the case of Cleveland St, in peak times. Forcing SH locals onto already congested roads as a by-product of providing a transport solution to ease congestion on these exact roads is not the required outcome.
Travelling time for a relatively simple commute would also be increased dramatically by being forced to use major arterial roads. Once again, this project is meant to be a transport solution, not make it worse.
SH locals are entitled to a LOCAL east-west corridor without having to use Foveaux (west) or Albion (east). It is quite appropriate for locals to be able to traverse our own suburb without being forced towards Central Station, for example, and having to negotiate more traffic lights, intersections and pedestrians.

Road Closures at Devonshire St
Proposed road closures at Devonshire St include Holt, Waterloo, Steel Ln, Adelaide Place and Little Riley St. Placing ballards along all streets on the northern side of Devonshire will significantly reduce those residents access to their homes (ie. properties facing Devonshire St have rear-lane access) and will impact how long it will take them to get in/out of SH. They will be forced into the other residential streets to be able to access, for example, Chalmers St, thus reducing the very thing the CSELR proposes to maintain: the village feel of Surry Hills.

Keep Devonshire St open to two-way traffic
One proposal by the Save Our Sydney group is for the light rail to go east up Devonshire and west down Foveaux. Devonshire St could then be open to two-way, LOCAL traffic; overcoming the issues for the LOCALS outlined above.
Alternatively, there could be provision for cars to follow the light rail (LR), as happens in European cities. If the speed limit for the LR is 30km/hr (which is the maximum speed currently on Devonshire St due to the volume of traffic and narrowness of road), then this keeps the car speeds in check and will remove the `fear' of some that Devonshire St will be used as a `rat run'.

Open Cooper St at Riley St to a shared zone
An alternative for LOCALS may be to re-open Cooper St to a single lane, shared pedestrian-car zone to improve access if Devonshire St is confined to a single lane. However, the cycle way must be moved to a more direct route.

NEED 2 STOPS, AT LEAST, IN SURRY HILLS
Currently, the CSELR has ONLY ONE STOP allocated for SH, at Ward Park. I support the CSELR as a transport solution for SH and the CBD/inner east. However, having only one stop effectively makes SH as POORLY SERVICED as it is now by public transport. This will make the CSELR more `white elephant' rather than `valuable infrastructure'.
In Europe, LR stops are 750m apart. Given the high population density of SH and surrounds, more than one stop is quite justifiable. Need another stop at the current site of Wimbo Park/ Olivia Gardens, at the very least, with a third stop towards the western end of Devonshire St.

Aesthetic, functionality and quality of Stops, Smart-poles, Paving, Lighting and Street furniture

This is a picture of European LR. There is the opportunity to integrate the LR so that it is functional and pleasing.



Removal of well-established trees on Devonshire St
The old, well-established trees on Devonshire create its charm and village feel. Removing these trees will remove the charm and village feel of the area.
The EIS claims trees will be replaced at a ratio of 8:1. Where? And what type of trees? Saplings to replace mature trees will not re-create the current village feel of SH.
There needs to be a transparent program of "greenifying" Devonshire St post LR construction. This plan needs to be developed now as part of the overall project plan.

Construction Noise and Disruption
I lived through the construction of the Eastern Distributor (ED) (at Nobbs St): a necessary and valuable piece of infra-structure, which I fully supported. However, construction of major works is disruptive. During that time, transport NSW provided constant updates in writing, a number of public meetings and the opportunity to consult with or complain to their liaison personnel. I found it to be a professional, inclusive approach and expect this standard to be met or, indeed, exceeded in this project.

Hours of Operation through SH
It is not appropriate to have LR operating past midnight on Fri and Sat, not after 11.00pm other nights and not before 6 am.

Community Consultation
The recent EIS community meeting was professional and informative. The staff were polite and knowledgeable and have, clearly, been immersed in this project for some time.
The glaring omission in the roll-out of this project to date has been the lack of basic consultation with the community that call SH `home' prior to the public announcement being made. From now on I hope that this omission will be rectified and consultation begun in earnest. There are still many questions that need to be answered and issues addressed to ensure that this vial piece of infra-structure for Sydney is a welcome and well-utilised asset for both locals of Surry Hills and visitors to our village.

Please see attached submission.

Comments from the NSW Small Business Commissioner

I have attached my submission whereby I do not agree with elements of the CSELR as stated in the CSELR EIS.

The website was not allowing me to upload my submission without included text in this box (despite being advised above that my submission can be either typed in this column or uploaded).
PLEASE NOTE:
I have attached my submission below:
CSELR - response to Environmental Impact Statement dated 241213.

As per attached file

Please see attached document

Please refer to the attached

While we are supportive of any improvement to Sydney's public transport network, the proposed surface route along Devonshire Street will have major detrimental effects on the many businesses and residents situated on Devonshire Street and throughout the whole of Surry Hills both during construction and particularly when the CSELR is in operation.

We request that the planned route along the surface of Devonshire Street be reconsidered and replaced with a sub-surface option which will have far less impact on the businesses and residents of Surry Hills. A "cut-and-cover" option beneath Foveaux Street has been identified as a feasible and cost effective and more direct alternative by a local engineer. Alternatively, if the government insists that the Devonshire Street route is to proceed, then a sub-surface "cut-and-cover" option should be implemented.

In order to maintain transparency, the government should release details of all cost-benefit analysis and all technical reports which it has relied upon to determine the chosen route through Surry Hills. We believe that a surface route along Devonshire Street, owing to it's narrow width and the resultant local traffic congestion, will be a major limiting factor for any future expansion of the CSELR. These limitations would not exist if a sub-surface route was implemented.

Full details of our submission and our specific concerns are within the attached PDF.

Submission is in the Attachment file

CSELR EIS Submission
My focus is the Surry Hills section of the proposed light rail network.
As a third generation resident of Surry Hiils, I object to the manner in which the plan was forced upon the community and the lack of consultation or negotiation.The government has not been transparent. I believe the arguments for selecting Devonshire Street are weak and narrow.

I object to the unnecessary destruction of a heritage suburb, precious parkland and peoples' homes when alternatives are viable - Oxford Street was designed as a tram route, the Foveaux Street concept merits further consideration.

I object to the EIS Devonshire route being the only one seriously
considered/evaluated publically. Surry Hills is a unique area. The impact of the proposed route must be lessened at all possible opportunities.

My concerns with the EIS impacts during and after construction for the proposed
Devonshire route are:
1. Traffic and Parking
There is potential for peak hour gridlock with congestion at intersections with Crown, Bourke and South Dowling Streets. South Dowling Street will have traffic lights every few blocks from Cleveland St to Foveaux St.
How will these be coordinated? Will there be warning lights for pedestrians
of oncoming trains?
Stop-start traffic creates increased pollution levels, a community health issue/risk.
The loss of over 128 parking spaces will result in a greater load on surrounding streets, which are already at capacity most of the time.
Langton Clinic will be seriously impacted with loss of parking and constant rail movements. This is a health and safety and access issue.
Access for emergency and residents between Elizabeth and Crown Streets appears very restricted. Potential hazards.
90 m trains on sporting/event days, running every few minutes could bring traffic on South Dowling and Crown Street to a halt or have trains backed up causing delay. It would be better to have shorter trains (30m) moving at a steady pace to allow traffic flow and safe people movement.

Suggestion - Reduce the rail speed limit to 20km along Devonshire Street to ensure safety around special interest sites (schools, churches) and safeguard the pedestrian quality of the area. 30 m trains only.
Suggestion - Increase residents only parking zones (side streets) and supply passes to residents for visitors.
Suggestion - Make some parking available in Olivia Gardens vacant area along with replaced park.
2. Trees and Moore Park.
The removal of around 140 trees is environmental vandalism.
The possible removal of Moreton Bay Figs in Moore Park is heritage destruction.
Using Moore Park as a parking lot /dumping ground will further degrade the park and cost vast amounts to restore.
The tunnel entrance to Moore Park is substantial and impact harshly on the western landscape.

Suggestion - No overhead wires/lines in Devonshire Street so that trees
maybe preserved. Use the latest technology.
Suggestion - It will be necessary to dig a tunnel under Anzac Parade. Begin this tunnelling in Moore park east to avoid destruction of heritage trees.
Suggestion - Parking at Randwick Racecourse only.
Suggestion - Ensure that the tunnel entrance/exit has maximum cover to align closely to the original surface.

3. Olivia Gardens and local business
Residents deserve appropriate compensation for losing their homes.
Local business in the whole surrounding area will suffer during
construction, which also warrants compensation.
EIS suggested 14 months to demolish Olivia Gardens. This seems an extremely long time. Is this indicative of the pace of work?
There is an arrogant, disinterested attitude to the hardship the
construction will inflict.

Solution - Compensate business with rental subsidies. Pay market price for acquisition of property.

4. Size, Noise, Speed, Frequency.
Suggestions:
LRVs max.29m through residential areas at surface level
Speed limit 20 km from South Dowling Street to Elizabeth Street.
Reduce noise and vibration levels to within EPA guidelines by using state of the art continuous rail along Devonshire Street to eliminate sound of wheels on expansion joints. Use high resilience track forms to reduce noise. INNORAIL system is effective ( www.trb.org )
Significant screening in residential areas must take place.
Double glazing for homes and business directly affected is essential, especially Langton Clinic, childcare centres, churches etc.
Operational times between 5.30 am and 11.30pm through Surry Hills
Frequency of LRV's to be limited to a minimum 5 minutes gap in both directions to allow for pedestrians, cyclists and vehicles to cross safely.
No PA system at Ward Park stop, this only increases intrusive noise for residents and is unnecessary.
Must have concession fares for Northcott residents.

5. Social, visual and environmental impact
I disagree with the assumption that changes to the local character will be moderately positive. Large trams travelling in both directions at high frequency will alter the environment irrevocably and effectively sever Surry Hills in two. It can be `landscaped', but it will be forever scarred and divided.
The EIS claims people will `get used to' the visual pollution of overhead wires and poles, along with tree destruction. The report (and government) demonstrates the lack of respect for the public. The community wants the best option and least impact.
Gardens and fences must be constructed to protect Northcott residents.
Pedestrian walkways must be ample.
As suggested in the EIS 13.9.3 all criteria during the construction phase has negative impact. Their should be some mechanism for complaint or compensation during this phase.

I recognise the importance of effective public transport and the appropriate use of light rail. My preference is for an alternative route through Surry Hills with state of the art technology. Given the present government position this seems impossible. I am deeply saddened and disappointed that a highly valued heritage area will be tragically transformed, that many lives will be negatively impacted upon, that Moore Park will be sacrificed
once again when the objective of moving people to and from other locations can be achieved without such major impact.

I request that the Oxford Street route and the Fouveaux Street option be reconsidered. I fear that the proposed route will be another example of poor public planning at outrageous costs like the Cross City tunnel and the Monorail, that does little to improve Sydney transport. I implore greater vision and less of a quick fix or the cheapest solution.
Vicki Kable
Ridge Street
Surry Hills